### Re: Boiler MACT PreambleRule Notes Link

RobertJ Wayland to

: Cortney Higgins, Jim Eddinger, Mary Johnson 12/20/2012 12:13 PM

From: RobertJ Wayland/RTP/USEPA/US

To: "Cortney Higgins" <Cortney_Higgins@omb.eop.gov>, Jim Eddinger/RTP/USEPA/US@EPA,

Mary Johnson/RTP/USEPA/US@EPA



### Cortney -

Our monitoring folks don't agree with making the suggested changes because we did not get any

public comments to support the change in the ar ea source rule. Call Mary (919-541-5025) if you

need a more detailed explanation.

Jim/I are working on your major source issues.

Bob

Sent from Blackberry Wireless Device

*********************************************

Dr. Robert J. Wayland

U.S. EPA

Office of Air Quality Planning and Standards

109 T.W. Alexander Drive, MC D243-01

RTP, NC 27709

Phone: (919) 541-1045

Fax: (919) 541-5450

Cell: (919) 306-2290

From: "Higgins, Cortney" [Cortney_Higgins@omb.eop.gov]

Sent: 12/20/2012 04:51 PM GMT

To: Jim Eddinger; Mary Johnson

Cc: Robertj Wayland

Subject: RE: Boiler MACT PreambleRule

HI Jim,

Any update on the question below regarding the area source rule?

Thanks,

CortneyFrom: Eddinger.Jim@epamail.epa.gov [ma ilto:Eddinger.Jim@epamail.epa.gov]

Sent: Wednesday, December 19, 2012 7:02 PM

To: Higgins, Cortney

Cc: Wayland.Robertj@epamail.epa.gov

Subject: RE: Boiler MACT PreambleRule

Cortney,

Our monitoring folks did edit those equations based on the earlier comments, but I w ill have them look at

this comment tomorrow if they feel Additional changes areneeded.

Jim

_______________ James A. Eddinger

Energy Strategies Group

Sector Policies and Programs Division

919-541-5426

"Higgins, Cortney" ---12/19/2012 05:29: 26 PM---Hi Jim, Below are a couple of interagency comments

that have come in today on this afternoon's draft

From: "Higgins, Cortney" < Cortney_Higgins@omb.eop.gov >

To: Jim Eddinger/RTP/USEPA/US@EPA

Cc: RobertJ Wayland/RTP/USEPA/US@EPA

Date: 12/19/2012 05:29 PM

Subject: RE: Boiler MACT PreambleRule

Hi Jim,

Below are a couple of interagency comments that have come in today on this afternoon’s drafts:

Major Source Rule.

Page 198. For consistency with equation 10, we believe the symbols X1 and Y1 in equation 11 should be small x

prime (small x with a bar over the top) and small y prime (small y with a bar over the top). (Rephrased version of

comment that was submitted by the SSC on 18 December 2012.) As an aside, in equation 10, perhaps X1 and Y1

should be Xi and Yi since it is a summation equation from i to n.

Area Source Rule.

Consider revising the definitions of 10

‐ day rolling average and 30

‐ day rolling average in the area source rule to be

consistent with the major source rule to incorporate the 240 hour and 720 hour of valid operating data criteria,

respectively. Both rules should probably exclude hours during startup and shutdown as well as unit down time,

from the rolling average calculations.

Regards,

Cortney

From: Eddinger.Jim@epamail.epa.gov [ mailto:Eddinger.Jim@epamail.epa.gov ]

Sent: Wednesday, December 19, 2012 3:50 PM

To: Higgins, Cortney

Cc: Wayland.Robertj@epamail.epa.gov

Subject: RE: Boiler MACT PreambleRule

Cortney,

Please replace the redline version I sent you earlier th is afternoon with this version. A few edits weremade to the fourth year language on pages 26 -28.



### (See attached file: EO 12866 NESHAP for Ma jor Sources Industrial, Commercial, and

Institutional Boilers and Proce ss Heaters 2060 121912 redline w 121312v2.docx)

Jim

_______________ James A. Eddinger

Energy Strategies Group

Sector Policies and Programs Division

919-541-5426